Shipper's Responsibilities

At UC Irvine, shippers are directly responsible for the correct packaging, labeling, documentation, and record retention, for hazardous materials shipped by air, land, and sea. This mean that if you package and offer to commercial carriers any materials that pose radioactive, chemical, biological or physical hazards you must be certified through successful completion of relevant training on hazardous materials shipping. Additionally, anyone who offers advice on packaging, labeling, and documentation for hazardous materials shipping, must possess relevant training certification. (Code of Federal Regulations (CFR) 49, Part 172-H).

Prior to shipping research equipment or materials out of the United States, and to ensure timely and compliant shipping of export controlled items, perform an export control review. Violation of export controls regulations can result in both civil and criminal penalties for the individual.

Shippers at UC Irvine pass trainings to be certified for hazardous materials shipping. To achieve certification to package and offer hazardous materials to commercial carriers, you must complete the foundation course described below and all "function-specific" trainings appropriate for the hazardous materials you intend to ship.

Foundation Course

Shipping Hazardous Materials: Regulations, Safety & Security - This course meets three (3) of the four (4) regulatory training requirements and is a prerequisite to further hazardous materials training. This course is available on-line through the UC Learning Center. Look in the course catalog using keyword "Shipping".

Function Specific Courses

This series of courses train shippers to package, label, and document shipments of specific materials. Function-specific courses are developed for specific hazardous materials determined to be shipped most often. EH&S continues adding online function-specific courses to meet changing campus needs.

If you do not see an online function-specific training for the hazardous material you ship, contact EH&S for assistance at 949-824-6200.

Hazardous Materials Shipping FAQs

1. What are Hazardous Materials?

Hazardous materials are articles or substances which are capable of posing an unreasonable risk to health, safety, property or the environment when transported by commercial carriers. Hazardous materials include hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, and materials which meet the criteria of one or more of nine United Nations (UN) hazard classes. A Material Safety Data Sheet (MSDS) indicates whether the material is hazardous and provides the UN hazard classification.

When minimal likelihood that pathogens are present, patient and animal samples and cell lines are not assigned to a UN hazard class; however, they still must be packaged and labeled as "Exempt human or animal specimens" by a trained person.

Non-infectious genetically modified microorganisms (GMMOs) and genetically modified organisms (GMOs) which are capable of altering animals, plants, or microbiological substances in a way which is not normally the result of reproduction are assigned to UN hazard Class 9. Infectious GMMO/GMO are assigned to UN hazard Class 6.2.

Formalin or gluteraldehyde (<10% solution) preserved specimens are not regulated. Minimize amounts per inner packaging, and use triple-pack to ship safely.

Magnetized material > 0.002 gauss @ 7 feet is assigned to Class 9.

Many types of batteries (lithium; sodium; potassium hydroxide; wet-filled with acid or alkali fluid) and battery-containing equipment/vehicles are considered dangerous goods usually assigned to Class 9.

Hazardous residues in machinery returned for repair is Class 9.

All radioactive materials (Class 7) must be shipped by EH&S.

3. What are infectious substances?

Infectious substances are substances which are known or are reasonably expected to contain pathogens. Pathogens are defined as micro-organisms (including bacteria, viruses, rickettsiae, parasites, fungi) and other agents such as prions, which can cause disease in humans or animals. Infectious substances are divided into two groups: Category A and Category B.

Category A is for an infectious substance which is transported in a form that, when exposure to it occurs is capable of causing permanent disability, life-threatening or fatal disease in otherwise healthy humans or animals.

Category B is for an infectious substance which does not meet the criteria for inclusion in Category A.

4. When are genetically modified organisms/micro-organisms (GMO/GMMO) considered hazardous materials?

The researcher must complete a hazard determination based on the GMO/GMMO’s ability to pose unreasonable risk to health, safety, property or the environment, if released accidentally from packaging. If infectious, the organism is shipped as Infectious Substance Class 6.2 Category A or Category B. If the organism is not infectious, the GMO/GMMO is shipped using Triple-Pack procedures for Miscellaneous Class 9. Follow the GMO/GMMO shipping procedures located on the Hazardous Materials Shipping webpage. GMO/GMMO cannot be shipped as Excepted Quantities or Exempt. An example of shipping a non-hazardous GMMO is the non-pathogenic modified e.Coli commonly used in recombinant DNA research.

5.What are Exempt Human and Animal Specimens?

Human, lab rat & mouse specimens with minimal likelihood that pathogens are present. Minimal likelihood that pathogens are present is determined by the shipper's professional judgment using the following basis: known medical history; symptoms and individual circumstances of the source, human or animal; endemic local conditions. If exempt, use Triple Pack to ship.

Commercial Invoices are generated by the shipper to declare the monetary value of exported goods. The declared value is used by foreign customs agents to assess monetary duties that need to be paid before the package clears customs. You can use FedEx Commercial Invoice tool to generate a Commercial Invoice, or obtain a blank form from your international carrier. It is common that a small quantity of research material sent to foreign colleague has neglible monetary value.

9. What is a Shipper's Declaration of Dangerous Goods?

A Shipper's Declaration or "Shipper's Dec" is a document completed and signed by a certified trained shipper. It is a declaration by the shipper that the hazardous material has been packaged according to regulations. It must be printed in color and has a red hash mark border. Regulations require that the form is completed in triplicate and the three copies accompany the package during transportation. Note: FedEx requires four copies. A copy of each Shipper's Declaration must be maintained by the shipper for 24 months. Any packages requiring a Shipper's Declaration must be coordinated through EH&S or Physical Sciences Shipping & Receiving--if in that school--in order to have copies of Shipper's Declarations available for DOT and FAA inspectors. Shippers must use FedEx Ship Manager Software to generate the shipper Declaration.

De minimis exception applies to shipments within the United States of Packaging Group II and III materials in Class 3, Division 4.1, Division 4.2, Division 4.3, Division 5.1, Division 6.1, Class 8, and Class 9, for inner packaging maximum quantities of 1 mL or 1 g, and maximum outer packaging maximum quantities of 100 mL or 100 g. Pack items using the drop and compression tested triple-pack. No hazard labels, markings, declarations are required. For air transport, the material must be approved for passenger-carrying aircraft (see Column 9A of DOT Hazardous Materials Table), and de minimis quantities cannot be carried in checked or carry-on baggage. The shipping company must accept packages under DOT regulations.

12. What are "excepted quantities"?

Excepted quantities are small quantities of hazardous materials ranging from 1 mL(g) to 30 mL (g) depending on the materials hazard level. You needknow how to use the material's E-code, triple-pack, and specialpackage markings, so you need to pass function-specifictraining for certification to ship excepted quantities.

13. What is triple-pack?

Triple-pack is tested packaging suitable for shipping de minimus, excepted, and limited quantity hazardous materials. The 1st layer in the triple-pack is the primary sample container known as the inner packaging. It must be leak proof and chemically compatible with the material, and its closure held securely in place with tape or other positive means. Cushion multiple inner packagings from touching each other and place them inside the intermediate packaging (the 2nd layer) like sealable leak proof plastic bag or canister with enough absorbent materials to completely absorb the entire contents of the inner packages. Place the sealed plastic bag in a sturdy, damage-free outer cardboard box, a.k.a. the outer packaging (the 3rd layer). Use crumpled paper or other space filler to fill voids between the intermediate packaging and outer packaging to block the intermediate package from moving around. The triple-pack has been compressive load and drop-tested from 7 feet to withstand the normal conditions and stresses of transport.